INDEPENDENT VERDICT
M.D. Sass requires more careful entity verification than its long operating history initially suggests because two similarly named adviser records now tell very different regulatory stories. M.D. Sass Associates Inc., CRD 110596 / SEC File No. 801-8670, shows an SEC registration termination dated March 31, 2023, while the currently active operating adviser is M.D. Sass, LLC, CRD 110590 / SEC File No. 801-8663. The current firm's March 31, 2026 Form ADV identifies M.D. Sass, LLC at 55 West 46th Street, Suite 2801 in New York and reports approximately $2.064 billion in discretionary regulatory assets under management as of December 31, 2025. This entity transition is the key diligence fact: finding the terminated M.D. Sass Associates record does not mean the M.D. Sass investment business disappeared or lost its current adviser registration. The active LLC continues under a separate CRD and 801 number, is owned directly or indirectly by Martin D. Sass and Ari D. Sass, manages institutional and high-net-worth accounts, and now spans private funds, separately managed strategies and a public ETF. The brand is therefore highly verifiable, but anyone checking regulatory status must use the current legal entity rather than the older terminated adviser record.
THE PORTABLE ALPHA FUND IS NOT A NORMAL "$3 BILLION FUND" STORY
The most unusual private vehicle is M.D. Sass Government Agency Portable Alpha, L.P., a Delaware limited partnership established in September 2019. M.D. Sass's current adviser brochure states that the fund invests primarily in U.S. government agency-issued or guaranteed mortgage-backed securities, collateralized mortgage obligations and similar high-credit-quality securities, while also using interest-rate and equity futures and/or swaps. That combination matters because "portable alpha" is structurally different from a conventional long-only fixed-income fund: the portfolio can pair a high-quality fixed-income base with derivative exposures intended to generate or transport additional return. Historical adviser data has reported private-fund gross assets substantially above the manager's regulatory AUM, including approximately $3.3 billion of gross assets for the Portable Alpha vehicle in prior ADV reporting while the manager's later 2025 year-end RAUM was about $2.06 billion. Those figures measure different things. Gross private-fund assets can incorporate leverage, derivatives and gross exposure, whereas regulatory AUM is calculated under adviser-reporting rules and should not be treated as identical to fund gross asset value. The fund has also appeared in public pension documentation: the Western Conference of Teamsters Pension Plan reported a very large investment in the vehicle in its 2023 Form 5500 materials, giving the fund an independently observable institutional-investor trail rather than only sponsor-generated marketing.
A 50-YEAR BRAND THAT CHANGED LEGAL WRAPPER — AND THEN ADDED A SECOND PRIVATE FUND
The legal continuity becomes clearer when the SEC record is read alongside the firm's own disclosures. M.D. Sass describes itself as an independent investment manager with more than 50 years of history, while the current LLC was formed in Delaware in November 2023. The new LLC did not create the underlying investment franchise from scratch; instead, current regulatory filings show Martin D. Sass as Chairman, CEO and CIO and Ari D. Sass as President, preserving leadership continuity while the adviser's legal wrapper changed. By 2026 the private-fund platform had also expanded beyond Portable Alpha. The current brochure identifies M.D. Sass Income Opportunity, L.P., formed in Delaware in February 2025, as a second private fund. That vehicle is described as investing at least 80% of assets in a multi-sector fixed-income portfolio spanning U.S. and non-U.S. public and private issuers and potentially using derivatives and other income-oriented structures. This is important because an article focused only on the Portable Alpha Form D would miss a broader evolution: M.D. Sass is no longer just an institutional SMA manager with one bespoke hedge fund, but a platform combining traditional accounts, multiple private vehicles and increasingly productized public-market access.
CONCENTRATED VALUE WENT FROM $1B TO $2B — THEN BECAME A PUBLIC ETF
The sharpest product-development story sits outside Form D. M.D. Sass announced that its Concentrated Value strategy crossed $1 billion in AUM in February 2024 and then exceeded $2 billion by May 2025, roughly doubling in a relatively short period. The strategy was launched in January 2019 and is managed by Ari Sass using a high-conviction value process rather than a broad index-like portfolio. On March 4, 2026, the firm took another step by launching M.D. Sass Concentrated Value ETF under ticker SASS, its first ETF, with the stated goal of bringing the same institutional Concentrated Value approach into a transparent exchange-traded structure. That creates a rare three-format business model under one manager: institutional separately managed accounts, private funds such as Portable Alpha and Income Opportunity, and a listed ETF carrying the M.D. Sass name. For diligence, these products must remain separate. The ETF does not provide exposure to the Portable Alpha strategy; Concentrated Value AUM should not be treated as private-fund AUM; and Form D capital raised by a private vehicle does not represent assets of the public ETF.
WEBSITE / ENTITY PENETRATION AND SERVICE-PROVIDER EVIDENCE
The current official domain is mdsass.com, and the leadership names, New York location and product descriptions align with current M.D. Sass, LLC regulatory records. The crucial regulatory numbers are CRD 110590 and SEC File No. 801-8663 for the active adviser. The older M.D. Sass Associates Inc. record, CRD 110596 / SEC 801-8670, is a separate terminated entity and should not be used to describe current registration status. Current adviser reporting also provides institutional infrastructure evidence beyond the manager's own website: 2026 adviser data identifies major custodial relationships involving State Street and Northern Trust for substantial separately managed assets, while prior disclosures also referenced J.P. Morgan and BNY Mellon. Public fund-service data additionally associates RSM with the Government Agency Portable Alpha fund. These relationships do not independently validate investment performance, but they help establish that M.D. Sass operates through an institutional service-provider network rather than only through internally generated marketing materials. No evidence reviewed indicates that the firm's CRD or SEC number is presented by M.D. Sass as an SEC endorsement; the regulatory identifiers function as registration references, not investment-quality certifications.
FINAL ASSESSMENT
The most important fact about M.D. Sass in 2026 is not a single Form D amount. It is the coexistence of an old investment brand, a newer legal adviser entity, a large and structurally unusual portable-alpha private fund, a second fixed-income private fund, a rapidly scaled Concentrated Value strategy and a newly launched ETF. The current SEC adviser record confirms M.D. Sass, LLC as the active registered adviser, while the terminated M.D. Sass Associates Inc. record explains why a superficial regulator search can create confusion. The Portable Alpha fund adds another layer because its gross exposure can materially exceed simple adviser-level AUM comparisons and because derivatives and agency-mortgage securities make headline asset figures less intuitive than in an ordinary equity fund. Investors evaluating a specific M.D. Sass product therefore need to identify exactly which legal vehicle they are entering and avoid transferring performance, AUM or risk characteristics from one product to another. The regulatory and institutional evidence strongly supports the existence and continuity of the manager, but the SEC records confirm registration and offering history rather than approving any individual strategy.
SEC SNAPSHOT
Brand: M.D. Sass Current Legal Adviser: M.D. Sass, LLC CRD: 110590 SEC Adviser File No.: 801-8663 CIK: 0000922940 Current Form ADV Date: March 31, 2026 Principal Office: 55 West 46th Street, Suite 2801, New York, New York 10036 Phone: 212-730-2000 Regulatory AUM as of December 31, 2025: $2,063,871,233 Discretionary AUM: $2,063,871,233 Ownership / Leadership: Martin D. Sass and Ari D. Sass Chairman / CEO / CIO: Martin D. Sass President: Ari D. Sass COO / General Counsel / CCO: Bobby Liu
Former Adviser Entity: M.D. Sass Associates Inc. Former Entity CRD: 110596 Former SEC File No.: 801-8670 SEC Registration Status: Terminated Termination Date: March 31, 2023
Important Entity Conclusion: The terminated M.D. Sass Associates Inc. adviser record should not be confused with the currently active M.D. Sass, LLC adviser registration.
PRIVATE FUND PENETRATION
M.D. Sass Government Agency Portable Alpha, L.P. CIK: 0001789624 Entity Type: Limited Partnership Jurisdiction: Delaware Established: September 2019 Investment Manager: M.D. Sass General Partner: M.D. Sass Portable Alpha GP, LLC Strategy: Agency MBS, CMOs, high-quality fixed income, futures and swaps Federal Offering Structure: Regulation D / Rule 506 Latest Reviewed Form D Amendment: September 30, 2025 Form D Signer: Bobby Liu Signer Role: General Counsel of Investment Manager
Historic ADV Private-Fund Gross Assets: Approximately $3.3 billion in prior reporting
Important Interpretation: Gross fund assets can exceed adviser RAUM because gross exposure and leverage are different regulatory measurements from adviser-level net regulatory assets.
Institutional Investor Evidence: Western Conference of Teamsters Pension Plan publicly reported a large investment in M.D. Sass Government Agency Portable Alpha, L.P. in its Form 5500 investment schedules.
SECOND PRIVATE FUND
Fund: M.D. Sass Income Opportunity, L.P. Jurisdiction: Delaware Established: February 2025 Investment Manager: M.D. Sass, LLC Strategy: Multi-sector fixed income Minimum Portfolio Requirement Stated by Adviser: At least 80% in fixed-income securities Potential Instruments: U.S. and non-U.S. public and private debt, derivatives and income-oriented structures
Research Significance: The 2025 Income Opportunity launch shows that M.D. Sass's private-fund business has expanded beyond the long-running Portable Alpha vehicle.
CONCENTRATED VALUE / ETF EVOLUTION
Strategy: M.D. Sass Concentrated Value Strategy Inception: January 2019 Portfolio Manager: Ari Sass
AUM Milestone: February 2024: Crossed $1 billion
AUM Milestone: May 2025: Crossed $2 billion
Public Product Launch: M.D. Sass Concentrated Value ETF Ticker: SASS Launch Announcement: March 4, 2026 Structure: Exchange-Traded Fund Manager: Ari Sass Firm Significance: First ETF launched by M.D. Sass
Important Distinction: Concentrated Value strategy AUM, SASS ETF assets, private-fund gross assets and total M.D. Sass regulatory AUM are separate measurements and should not be combined.
SERVICE-PROVIDER / INSTITUTIONAL INFRASTRUCTURE
Current Adviser Custody Relationships Publicly Reflected in 2026 ADV Data: State Street Northern Trust
Other Historically Reported Custodians: J.P. Morgan BNY Mellon Merrill Lynch
Portable Alpha Auditor Identified in Public Fund-Service Data: RSM
Institutional Client Base: Pension and profit-sharing plans represent a substantial component of reported adviser assets. High-net-worth individuals, corporations, charitable organizations and pooled investment vehicles also appear in adviser reporting.
FIVE FACTS UNIQUE TO THIS CASE
- The similarly named M.D. Sass Associates Inc. SEC adviser registration terminated in 2023 while the active adviser is M.D. Sass, LLC under a different CRD and SEC file number.
- Government Agency Portable Alpha combines agency mortgage securities with futures and swaps rather than operating as a conventional long-only bond fund.
- Private-fund gross assets have historically exceeded adviser-level RAUM, making headline size comparisons particularly easy to misread.
- Western Conference of Teamsters pension disclosures independently identify a major institutional investment in the Portable Alpha vehicle.
- M.D. Sass transformed its Concentrated Value strategy from institutional mandates into its first ETF, ticker SASS, in March 2026 after the strategy crossed $2 billion in AUM in 2025.
CORE INVESTOR QUESTIONS
- Which current M.D. Sass legal entity is named in the investment-management or subscription agreement
- Is the investor entering Government Agency Portable Alpha, Income Opportunity, a separately managed account or the public SASS ETF
- What caused the legal-adviser transition from M.D. Sass Associates Inc. to M.D. Sass, LLC
- Were client contracts and fund-management responsibilities formally transferred when the current LLC structure was established
- How much economic leverage is embedded in Government Agency Portable Alpha through futures, swaps and mortgage-related instruments
- How should current net asset value be reconciled with historical gross private-fund assets reported in Form ADV
- Is Government Agency Portable Alpha still dominated by one or a very small number of institutional beneficial owners
- What management and performance fees apply specifically to Portable Alpha
- How does Income Opportunity differ from M.D. Sass's traditional institutional fixed-income accounts
- Are securities or investment ideas allocated across private funds, SMAs and registered products using a documented allocation policy
- How much of Concentrated Value's reported strategy AUM now sits inside the SASS ETF versus institutional accounts
- Which auditor, administrator, custodian and prime broker currently service each private fund
ENTITY-SPECIFIC RISKS
Agency mortgage securities can carry significant duration, convexity and prepayment risk even when credit risk is low. CMO structures can react differently to rate changes depending on tranche and cash-flow characteristics. Futures and swaps can create gross exposure materially larger than investor net capital. Portable-alpha construction can produce basis risk between the high-quality fixed-income portfolio and the return-generating overlay. A fund with a concentrated institutional ownership base can face meaningful liquidity consequences if a large investor redeems. The 2023 adviser-entity transition makes it important to verify current legal contracts rather than relying on legacy M.D. Sass entity names. The same M.D. Sass brand now covers strategies with very different liquidity and risk profiles, including private hedge funds, institutional SMAs and a public ETF. Concentrated Value's rapid AUM growth should not be used as evidence of performance for Portable Alpha or Income Opportunity. Private-fund gross asset values are not directly comparable with adviser regulatory AUM. Mortgage and derivatives exposures cannot be reconstructed completely from ordinary public equity holdings reports.
PRIMARY EVIDENCE REVIEWED
SEC Form ADV filed March 31, 2026 for M.D. Sass, LLC, CRD 110590 / SEC File No. 801-8663. SEC Investment Adviser Public Disclosure record for former M.D. Sass Associates Inc., CRD 110596 / SEC File No. 801-8670. Current M.D. Sass Form ADV Part 2 brochure describing Government Agency Portable Alpha and M.D. Sass Income Opportunity. SEC Form D and Form D/A records for M.D. Sass Government Agency Portable Alpha, L.P. M.D. Sass official announcement that Concentrated Value crossed $1 billion in 2024. M.D. Sass official announcement that Concentrated Value crossed $2 billion in 2025. M.D. Sass March 4, 2026 announcement launching the SASS ETF. Western Conference of Teamsters Pension Plan Form 5500 investment schedules. Public fund-service-provider records associated with Government Agency Portable Alpha.
IMPORTANT FORM D NOTICE
Form D records an exempt securities offering and does not represent SEC approval, endorsement, licensing or a determination that an investment is safe. Form ADV confirms adviser registration and disclosures but likewise is not an SEC endorsement of M.D. Sass or any specific strategy. The former M.D. Sass Associates Inc. and current M.D. Sass, LLC are distinct regulatory records and should not be conflated. FilingDossier independently compares issuer, adviser, institutional-investor, product and company records to identify which legal entity and investment strategy each public disclosure actually describes.